In
El Ali v R [2019] NSWCCA 207 the New South Wales Supreme Court of Criminal Appeal has considered an appeal by a man who apparently used Photoshop to alter an Australian Department of Defence export form to make it appear that he had permission to import firearm parts from Germany into Australia. Mr El Ali was unsuccessful in his appeal against conviction and sentence. The NSWCCA found that there was no duplicity in the prosecution's case as the offence of conspiracy differed from the substantive offence of possession. The NSWCCA also found that the NSW District Court had not erred in assessing the scope of the conspiracy, the subjective factors of the offender or in failing to find special circumstances.